HmeAdmin is committed to protecting the confidentiality and security of information we collect about our customers.

The Information We Collect

To provide our clients and their investors (collectively, “Clients”) with superior service, HmeAdmin may collect several types of nonpublic personal information about its Clients, including, but not limited to:

• Information from forms that Clients may fill out and send to HmeAdmin in connection with fund accounting and fund administration services (such as name, address, social security number, birthdates, assets, income and investment experience).
• Information Clients may give HmeAdmin orally.
• Information about the amount Clients have invested in a private investment fund (such as initial investment and any additions to and withdrawals from a capital account).
• Information about any bank account Clients may use for transfers between a bank account and a capital account of a private investment fund or an individually managed account.

HmeAdmin does not sell or disclose Service Recipient personal information to anyone except as permitted or required by law. For example, HmeAdmin may share information collected about its Clients with its legal counsel as it deems appropriate. Additionally, a copy of the Clients tax Form K-1 is included in a private investment fund’s tax return filed with the Internal Revenue Service. Finally, HmeAdmin may disclose information about Clients at their request (for example, by sending duplicate account statements to someone designated by the Client), or as otherwise permitted or required by law.

Commitment to Security

Within HmeAdmin, access to information about Clients is restricted to those employees who need to know the information to service the Client accounts. HmeAdmin employees are required and trained to follow the firm’s procedures to protect Client privacy and are instructed to access information about Clients only when they have a business reason to obtain it. In addition to procedural controls, ATWeb employs a Logical Security database infrastructure, whereby data transmissions are managed through 128 bit SSL encryption.

HmeAdmin reserves the right to change its privacy policy in the future, but HmeAdmin will not disclose Client nonpublic personal information as required or permitted by law without giving the Client an opportunity to instruct HmeAdmin not to.